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Coalition 
0 primary responsibility for compliance to be trans- 
ferred to local biohazard committeess 
° the haste to lower standards of containment through 
revisions of the guidelines without experimental data 
to justify such revisions 
The following comments address the need for structural and procedural 
changes. 
I. StMietafie o £ the NJH R Ecombtnant VMA \d\)-Lt>ony Committee. (RAC) 
The RAC was originally established and defined to treat technical 
questions arising in connection with research funded by NIH ( Federal Reg- 
ister 39, November 6, 1974, p. 39306). As presently constituted, it is 
not well-equipped to address questions of management and control. Nor is 
it sufficiently representative of the sectors that will be affected by 
recombinant DNA technology to address questions concerning the social good. 
Two courses of action are open: 
Either : the committee remains as a technical committee, in which 
case another committee would need to be designed to examine 
non-technical questions. 
Or : the committee should be reconstituted in order to deal more 
effectively and in a representative fashion with the broad- 
er issues of social responsibility and control. 
The second alternative will probably be seen as more desirable, in 
terms of efficiency. In addition, a viable model for the second alter- 
native already exists: in Great Britain, responsibility for screening 
all recombinant DNA activities has been assumed by a broadly represent- 
ative committee, the Genetic Manipulation Advisory Group. (GMAG) . The 
GMAG advises the Health and Safety Commission which regulates recombin- 
ant DNA work under the Health and Safety at Work Act of 1974. The GMAG 
convenes subcommittees to deal with technical questions, but its member- 
ship is not predominantly technical. 
[A-284] 
